"In the United States District Court for the Eastern District of Virginia."
Mr. Kai K. Mong
4601 Player Lane
Virginia Beach, VA 23462
(757) 467-5048
Vs. Civil No.
Regent University School of Law (Mr. Thomas M. Diggs)
1000, Regent University Dr
Virginia Beach, VA 23464
Dated on October 10
I. Complaint
This is a civil action wherein the plaintiff, Mr. Kai K. Mong, alleges that Thomas M. Diggs (Regent University School of law), engaged in violation of our constitutional rights, and discrimination based on Title VI of the Civil Rights Act of 1964.
As stated in:
AMENDMENT XIV
Sec. 1. All persons born or naturalized in the US, and subject to the jurisdiction thereof, are citizens of the US and of the State wherein they reside. No State shall make or enforce any law, which shall abridge the privileges or immunities of citizens of the US; nor shall any State deprive any person of life, liberty, or property, without due process of law; or deny any person within its jurisdiction the equal protection of the lawsK.
Furthermore our Constitutional law prohibits discrimination as:
The limitation of most institutional norms to public actors has constituted one of the important dividing lines between public and private entities in America legal life. The expansion of federal spending, accompanied by statutory provisions imposing constitutional or analogous limitations on recipients of federal funds, is eliminating that distinction. Title VI of the Civil Rights Act of 1964, which prohibits discrimination in federally assisted programs. Regent University participates in Title IV; therefore the University is responsible for their violation of Title VI of the Civil Rights Act of 1964.
According to Title VI of the Civil Rights Act of 1964:
601. No person in the US shall on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance. [42 U.S.C. 2000d]
602. Each Federal department and agency which is empowered to extend Federal financial assistance to any program or activity, by way of grant, loan, or contract other than a contract of insurance or guaranty, is authorized and directed to effectuate the provisions of section 2000d of this title with respect to such program or activity by issuing rules, regulations, or orders of general applicability which shall be consistent with achievement of objectives of the statute authorizing the financial assistance in connection with which the action is taken.
The said section bans discrimination based on the ground of race, color, or national origin, in any program or activity receiving Federal financial assistance. The School involved in this litigation receives large amounts of federal financial assistance. The Department of health, Education, and Welfare (HEW), which has authority to promulgate regulations prohibiting discrimination in federally assisted school system, 42 U.S.C. 2000d-1, in 1968 issued one guideline that [s]chool systems are responsible for assuring that students of a particular race, color, or national origin are not denied the opportunity to obtain the education generally obtained by other students in the system. 33 Fed. Reg. 4956.
By Section 602 of the Act HEW is authorized to issue rules, regulations, and orders to make sure that recipients of federal aid under its jurisdiction conduct any federally financed projects consistently with 601. HEWs regulations, 45 C.F.R. 80.3 (b) (1), specify that the recipients may not
(ii) Provide any service, financial aid, or any other benefit to an individual which is different, or is provided in a different manner, from that provided to others under the program;
K..
(iv) Restrict an individual in any way in the enjoyment of any advantage or privilege enjoyed by others receiving any service, financial aid, or other benefit under the program.
Discrimination among students on account of race or national origin that is prohibited includes discriminationKin the availability or use of any academicK or other facilities of the grantee or other recipient. 80.5 (b)
Discrimination is barred which has that effect even though no purposeful design is present: a recipient may notKutilize criteria or methods of administration which have the effect of subjecting individuals to discrimination or have the effect of defeating or substantially impairing accomplishment of the objectives of the program as respect individuals of a particular race, color, or national origin. 80.3 (b) (2).
Senator Humphrey, during the floor debates on the Civil Rights Act of 1964, said:
Simple justice requires that public funds, to which all taxpayers of all races contribute, not be spent in any fashion which encourages, entrenches, subsidizes, or results in racial discrimination. K
As the aforementioned above, the Federal Court has jurisdiction over the violation of our Constitutional Rights and Title VI the Civil Rights Act of 1964, which was committed by Thomas M. Diggs (Regent University).
II. Jurisdiction and Venue
1. Thomas M. Diggs is the director of LL. M program, and also he is associate professor at Regent University. Regent University is located in Virginia Beach, VA. Therefore this Court has a jurisdiction over Thomas M. Diggs unethical practices and racism.
2. Plaintiff filed charges of discrimination and retaliation in violation of Amendment XIV and Title VI of Civil Rights Act of 1964, with Civil Rights Office and within the limitation statute.
III. Parties
3. The plaintiff, Kai K. Mong (hereinafter Kai) is Asian-American citizen of the US. He is original from Burma.
4. Defendant Thomas M. Diggs (hereinafter Diggs) is a Caucasian and the Director of LL. M program at Regent University School of Law.
IV. Facts
5. A non-Burmese national origin was not charged Regent University Life Insurance Policy (Refer to Financial Statement Copy),
6. A non-Burmese national origin was allowed to write their domestic law related papers,
7. A Burmese national origin was not allowed to see his grade for LAW 911 (check with Family Compliance Office),
8. A Burmese national origin never got a response from Thomas M. Diggs for his thesis topics until Feb 16,
9. A Burmese national origin was not allowed to have the grievance committees decision within a month. The Chairman of the grievance committee never signed the decision letter. The letter was written and signed by Thomas M. Diggs,
10. A Burmese national origin was never protected by the School which he faced a hatred on campus,
11. A Burmese national origin was not allowed to have on-campus apartment,
12. A non-Burmese national origin was allowed to make copies as much as he wants. However, a Burmese national origin was banned,
13. A non-Burmese national origin was allowed to have their own password to access their blackboard in the fall of 1999,
14. A non-Burmese national origin can access to classroom without difficulties,
15. A non-Burmese national origin can access to their West Law and Lexis information,
16. A non-Burmese national origin can have their textbooks in the beginning of their class,
17. A non-Burmese national origins thesis/paper discs were never stolen,
18. A non-Burmese national origins loans were never returned to their lender without reason,
19. The School never reported to the lender of a non-Burmese national origin, while he is in his class as he is no longer a student at Regent University, but a Burmese national origin was reported,
20. A non-Burmese national origin can enjoy the Schools doubled-major program,
21. The School disturbed a Burmese national origins communication with a Jewish descent, Ann Siegel (Communication Student). It is needless to say that the School gets involved in anti-interracial dating. (Refer my letter to Senator Warner in June),
22. A Burmese national origin never got a resolution of his stolen wallet, books, money, and ring,
23. Someone removed a Burmese national origins important emails. According to the relevant facts, only Thomas M. Diggs knows his email address,
24. Lastly, the School never reported crime statistics to DOE.
I am a naturalized US, and I was accepted as LL. M student at Regent University in the Spring of 1999.in the Fall of 1999, I was accepted as LL. M and Government Policy as a joint degree program. According to the Student Handbook and LL. M brochure, there was no explanation about taking LL. M and Government Policy as a double major. However, I realized that some J. D students were working on LL. M also.
In the beginning of the Fall in 1999, I was not allowed to register for LL. M and Government Policy. I asked Dr. Selig (Provost) at that time, he told me that you cannot register for LL. M and Government Policy. However, you can register LL. M and other School except Government Policy. As a favor, I was allowed to register for one semester as a joint degree student. However, my accessibility to LL. M was blocked. I asked help from my professor (William Byrne), and he told me, Kai, they are harassing you, use my password. However, I was not able to post my assignment on the blackboard.in the end of the Fall in 1999, the School switched my grades from Government Policy to LL. M as a lower grade. I reported this unethical conduct from Provost to the President of Regent University, but there was no resolution reached.
In the Spring of I never got my textbooks until May. According to Thomas M. Diggs, he sent all books out to every student, but I never got one. Besides, when I was working on my papers in the Spring of my wallet and resource books were stolen by Howard Shannon who is the employee of Regent Law Library. I made a Police Report to 4th Precinct at Virginia Beach. My Report was taken by Officer Goss, and the Report number is 0409708. According to Officer Goss, Regent University is a private entity, therefore the Police Department has no jurisdiction over it. However, Regent University never solved this problem.
In October, I asked the Registrar Office to see my grades, but they were not willing to release it. Based on the information I got from Shawna was you are academically dismissed, therefore we cannot release your grade, so you need to contact Thomas M. Diggs. Therefore I tried to contact him, but there was no explanation at all.
In the Fall of Thomas M. Diggs blocked my accessibility to my class, therefore I wrote a letter to Dr. Pat Robertson. Because of that I was allowed back to my class in the Spring of 2001. However, my loan was returned to my lender without my consent. I asked Thomas M. Diggs for my thesis topic, but he never replied until February 16. Besides, my accessibility to LAW 910 was blocked. I never got my textbooks for LAW 916 until March 23. A week before the commencement date, my name was removed from graduation list by Thomas M. Diggs. Furthermore, my disc for thesis was stolen, and I made a Police Report at Chesapeake Police Station. My Report was taken by Officer Caldwell-Jones. The Report number is 01-41053.
I asked Thomas M. Diggs, what reason my name was removed from graduation list. According to his response:
H He doesnt have enough time to review my thesis.
H I need to redo on LAW 911
He showed me my LAW 911, on April 30. Therefore, I tried to redo on that paper, but he forced me to change the topic because the former topic was related to Burmese Customary Law. Thus, he picked, and forced me to write Charitable Remainder Trust.
Because of the aforementioned racism, I filed a petition with Dean Brauch, but there were many lies involved. Therefore, I filed an appeal with Grievance Committee on September 7. According to the Student Handbook, my appeal must be responded within a month. However, I never got their decision until November 4. Therefore I made a decision to visit my former country (BURMA) on the 6th of November. My passport was stolen on the 5th of November. I made a police report on November 8th. My report was taken by Officer Lewis at 4th Precinct at Virginia Beach. The report number is 073-891. On the same night, Thomas M. Diggs gave me the decision letter, which was written and signed by him. It was hand delivered. The next day he flew to New Zealand. I wrote a letter to Congressman Ed Schrock, so he gave me a special letter, therefore I got my replacement passport on November 20. On the same day, Thomas M. Diggs returned from New Zealand.
As the aforementioned above, the violation of my privacy; due process of law; under equal protection of the law, Regent University committed the said violation. Therefore I pray that I must be given the following relief:
1) I must graduate as of 2000.
2) Thomas M. Diggs is responsible for my loan repayment. This must be checked with Citibank.
3) Regent University is responsible for my potential job for 2 years. Based on $ 7000/month, so it must be $ 168,000.
4) Regent University is responsible for my loan restitution, US $ 18,600.
5) Regent University is responsible for my stolen wallet, US $ 26,000 500 in cash.
6) Regent University is responsible for my stolen US passport.
7) Regent University is responsible for my mental depression, based on. 20cents/second, US$ 12/minute, US$ 720/hr, US$ 17,280/day, US $ 518,400/month, and US $ 6,220, 800/year. Total US $ 24,883, 200 for four years.
8) Regent University is responsible for my doctorate studies.
9) To remove all unethical records made by Thomas M. Diggs at Registrar Office.
10) To remove Thomas M. Diggs from Regent University and revoke his license to practice as a lawyer in the US.
11) To stop the would-be retaliation in this case.
Cc:
Senator John Warner
Senator George Allen
Congressman Ed Schrock
Nony Abrajano, Chairman, Fil-American Organization
Each incident is documented; therefore supporting evidences are available upon request.
0 comments